Product Description - Data Loss Prevention and Data Access Governance Infrastructure Solution.docx

Data Loss Prevention (DLP) and Data Access Governance (DAG) Infrastructure Solution TAC Number: VA-26-00029054

PRODUCT DESCRIPTION (PD)

DEPARTMENT OF VETERANS AFFAIRS

Office of Information & Technology Infrastructure Operations

Data Loss Prevention (DLP) and Data Access Governance (DAG) Infrastructure Solution

Date: 12/19/2025

VA-26-00029054

PD Version Number: 3.0

Contents

background The Department of Veterans Affairs (VA) Office of Information and Technology (OI&T) and Infrastructure Operations are committed to delivering high-quality, effective, and efficient Information Technology (IT) services that enable safe, timely, and effective delivery of VA benefits, health care, and support services for Veterans through reliable and secure IT capabilities.

To support this mission, OI&T and Infrastructure Operations are charged with providing robust cybersecurity protections for Veterans, VA information, and VA information systems and infrastructure. We sustain and strengthen the resiliency of VA’s cybersecurity environment through proactive monitoring, rapid and adaptive response, and adherence to federal requirements.

In partnership with the Officer of Information Security (OIS), Infrastructure Operations must continue to mature the VA information security program to address known gaps, keep pace with an evolving threat landscape, reduce risk introduced by emerging technologies, and align with federal cybersecurity strategy and direction, including Executive Order (EO) 13800, Strengthening the Cybersecurity of Federal Networks and Critical Infrastructure, and EO 14028, Improving the Nation’s Cybersecurity.

As part of this effort, Data Loss Prevention (DLP) and Data Access Governance (DAG) is a critical component of VA’s defense-in-depth approach. VA’s DLP and DAG’s capabilities are intended to prevent and reduce the likelihood of data breaches and data exfiltration by monitoring, detecting, and blocking unauthorized disclosure of sensitive VA data regardless of where that data resides. These protections are implemented through software and hardware controls aligned with VA governance and maturing enterprise security standards. DLP and DAG protections must cover data at rest across the major cyber domains, including network, cloud, and storage environments.

VA has fully deployed the Varonis solution across the enterprise in a hybrid configuration maintained on-premises and within Enterprise Cloud Solutions Office (ECSO). As the vendor is deprecating its self-hosted architecture, VA is seeking to migrate its existing deployment to a SaaS solution to ensure continuity of enterprise DLP and DAG and data security capabilities.

VA is currently leveraging Varonis Data Advantage and Varonis Data Advantage for Active Directory to provide visibility, classification, and governance across approximately 4.2 billion on-premises files and all data at rest within VA’s Microsoft 365 environment. The VA enterprise deployment also includes licensing coverage for 700,000 users. VA also leverages Varonis Data Privilege to enable owner led access governance by supporting delegated approvals, workflow-based access requests, and least-privilege enforcement. This capability aligns with the VA Chief Information Security Officer’s objective of placing accountable data owners in charge of their data by enabling business owners to directly approve, review, and revoke access based on mission need, while maintaining oversight, auditability, and enterprise policy enforcement.

PRODUCT REQUIREMENTS

The Contractor shall develop, implement, update, and maintain a single-vendor Commercial Off-the-Shelf (COTS) solution for the VA Enterprise that provides DLP and DAG functionality as described in Table 1. This solution must deliver a fully functional, integrated, enterprise-wide infrastructure that meets all the requirements specified in this PD.

The solution shall include, but is not limited to, delivery, deployment, and configuration of the software and all related capabilities across VA IT Centers (ITC).

The Contractor shall provide licenses to support a minimum of 700,000 users for the entire period of performance. When the Base and any Optional Tasks are executed, all associated licenses shall be coterminous and expire on the last day of the performance period.

The period of performance shall include 1 12-month Base Period followed by 4 12-month Option Periods, and 1 Optional Task.

If an alternative vendor solution is proposed and selected for award, the awardee is responsible for maintaining continuity of operations by sustaining the existing Varonis licensing and support for the duration of the transition. The existing Varonis licenses include Automation Engine for Windows, DatAdvantage for UNIX/Linux, DatAdvantage for Windows, DatAlert Suite, Data Classification Framework for Unix, Data Classification Framework for Windows and SharePoint, Data Classification Policy Pack, Data Classification Labels, and Data Transport Engine. The awardee must complete the migration to the newly proposed solution within 90 days of contract award. The transition must be executed without degradation to VA’s security posture and without interruption to DLP and monitoring capabilities.

Table 1

2. The solution shall support the discovery and classification of data across various data stores. The vendor shall provide a list of supported data stores.

3. The solution shall be able to discover secrets and keys.

4. The solution shall have the ability to process large and increasing volumes of data in big data repositories.

5. The solution shall automatically update classification policies to reflect the latest rules and regulations.

6. The solution shall allow for the creation of custom classification rules.

7. The solution shall offer the ability to tune and reduce false-positives.

8. The solution shall provide customizable scan scoping.

9. The solution shall provide file analysis capabilities.

10. The solution shall use standard classification policies across different data stores.

11. The solution shall allow for the creation of custom rule-based classifiers.

12. The solution shall be able to scan various file types. The vendor shall provide a list of supported file types.

13. The solution shall support Optical Character Recognition scanning.

14. The solution shall have defined procedures for performing classification scans. The vendor shall describe how the solution performs these scans.

15. The solution shall have the capability to automatically apply labels to data.

16. The solution shall allow for the creation of custom labels.

17. The solution shall monitor and report on labeling progress.

18. The solution shall accommodate and appropriately handle already labeled files.

19. The vendor shall describe whether the solution accesses or retains sensitive customer data.

20. The solution shall have a local collector.

21. The solution shall provide the ability to show the location of data within the environment.

22. The solution shall offer contextual search functions to understand factors such as file type, sensitivity, user type, location, and other metadata.

23. The solution shall have the ability to locate all detected information pertaining to a given person to ensure compliance with data privacy regulations.

24. The solution shall be able to create a data asset inventory and catalog.

25. The solution shall facilitate compliance and enable adherence to common industry regulatory standards such as CCPA/CPRA, HIPAA, PCI DSS, NIST, and others.

2. The solution shall provide the ability to access controls, protection, archival, and disposal policies for sensitive data.

3. The solution shall have the capability to perform quarantine actions.

4. The solution shall be able to identify stale data.

5. The solution shall map granular permissions to data.

6. The solution shall analyze single sign-on (SSO) states across all assessed SaaS and Infrastructure as a Service Platforms.

7. The solution shall identify and visualize data access paths, permissions, and potential exposure points.

8. The solution shall identify and report on unique permissions.

9. The solution shall clearly depict the roles assigned to users on each platform.

10. The solution shall identify data owners.

11. The solution shall enable data owners to control access to their data.

12. The solution shall identify publicly exposed sensitive data.

13. The solution shall identify data shared externally.

14. The solution shall provide recommended actionable insights for data protection and risk reduction.

15. The solution shall display sharing links in context with data sensitivity and staleness.

16. The solution shall identify stale permissions for each user.

17. The solution shall have the capability to automatically revoke organization-wide and public sharing links.

18. The solution shall automatically revoke external user access to sensitive data.

19. The solution shall automatically revoke stale permissions to data.

20. The solution shall provide customizable remediation policies.

21. The solution shall provide a graphical view of data exposure in the form of dashboards.

22. The solution shall offer customizable dashboards.

23. The solution shall provide compliance dashboards and reports.

24. The vendor shall describe other reports provided by the solution.

25. The solution shall allow for the creation of custom reports.

26. The vendor shall describe how the solution allows for the configuration and extension of reports within the tool and whether it extends reporting beyond the platform, indicating the most widely used reporting and data analytics by existing customers.

27. The solution shall allow for the export of reports.

28. The vendor shall offer data risk assessments.

2. The solution shall have the capability to automatically fix misconfigurations in both SaaS and Infrastructure as a Service platforms.

3. The solution shall be able to integrate with workflow automation tools.

4. The solution shall have the ability to integrate with incident management systems (e.g., ServiceNow, Jira) to create tickets.

5. The solution shall provide a timeline view of the cloud environment, enabling the detection of posture changes and tracking the evolution of the system over time.

6. The solution shall analyze single sign-on states across all assessed platforms.

7. The vendor shall describe how the solution tracks multi-factor authentication across all assessed platforms, including for each user.

8. The solution shall assist in finding and fixing Active Directory misconfigurations.

9. The solution shall have the capability to assess password expiry settings.

2. The solution shall be able to identify anonymous user access.

3. The vendor shall describe how the solution identifies privileged users from external domains.

4. For user-related configurations, the solution shall enrich user settings data with relevant directory context (e.g., department, company).

5. The solution shall have the capability to identify privileged accounts.

6. The solution shall be able to integrate with Security Information and Event Management (SIEM) and Security Orchestration, Automation, and Response (SOAR) platforms.

7. The solution shall have the capability to identify stale group memberships.

Identity Security and Risk Management

1. The solution shall have the capability to identify external and personal accounts with access to data.

2. The solution shall be able to identify anonymous user access.

3. The vendor shall describe how the solution identifies privileged users from external domains.

4. For user-related configurations, the solution shall enrich user settings data with relevant directory context (e.g., department, company).

5. The solution shall have the capability to identify privileged accounts.

6. The solution shall be able to integrate with SIEM and SOAR platforms.

7. The solution shall have the capability to identify stale group memberships.

2. The solution shall identify suspicious or risky file activity that may indicate a threat, such as users accessing or downloading unusual amounts of data.

3. The solution shall perform automated responses to stop an attack.

4. The solution shall detect and alert on abnormal activity.

5. The solution shall record a timestamp of activity.

6. The solution shall detect identity-based risks and threats, including privilege escalation.

7. The solution shall detect potential threats to the system, including misconfigurations, external threats, and insider threats.

8. The solution shall provide recommendations for mitigating identified risks.

9. The solution shall provide insight into attack methods.

10. The solution shall map alerts to MITRE ATT&CK tactics and techniques.

11. The solution shall allow for the generation of custom alerts.

12. The solution shall maintain a normalized and historical audit trail of events.

13. The vendor shall describe how the solution utilizes AI.

14. The solution shall monitor AI usage.

15. The vendor shall specify how often threat models are updated.

16. The solution shall be able to send alerts directly to the necessary personnel.

17. The vendor shall provide a list of SIEM solutions that the solution integrates with.

18. The solution shall use webhooks, Syslog, APIs, or both to feed logs to SIEM solutions.

19. The vendor shall describe the process for exporting audit logs.

20. The solution shall provide an incident response team or services.

21. The solution shall be able to integrate with SOAR platforms.

22. The solution shall provide exfiltration detection capabilities.

23. The solution shall provide endpoint monitoring capabilities.

2. The solution shall have the capability to create custom review schedules and perform automated access reviews.

3. The solution shall provide a self-service portal for end-user access requests.

4. The solution shall manage permissions, monitor usage, and trigger remediation actions as necessary.

5. The solution shall integrate with existing agency workflows and tools.

2. The solution shall automatically reduce the blast radius and enforce least privilege on agency data sets.

3. The solution shall automatically optimize data storage based on usage and importance.

4. The solution shall automatically transfer data and stage data for migration.

2. . The solution shall be capable of scaling to handle increasing data volumes and user demand without degradation in performance. The vendor shall describe the solution’s scalability approach and any factors that may impact its ability to meet these minimum expectations.

3. The vendor shall describe how the product optimizes resource usage.

4. The platform shall be architected in an efficient and secure way to limit sensitive data from leaving agency boundaries.

2. The solution shall be certified in the following compliance standards: SOC 2, SOC 3, ISO, HIPAA, and NIAP Common Criteria.

REQUIREMENTS COMPLIANCE MATRIX

The Contractor shall complete and submit responses to each requirement in the Government-provided Requirements Table/Matrix. For every requirement, the Contractor shall indicate Meets, Partially Meets, or Does Not Meet, and provide a concise narrative response with traceability to the proposed solution, including references to supporting documentation. The Contractor shall maintain the matrix as a controlled artifact and update it as requirements are refined, clarified, or modified via contract changes.

section 508 accesSibility compliance package The Contractor shall provide a Section 508 Compliance Package for the proposed solution and for any end-user interfaces, administrative consoles, and user-facing reports delivered under this contract in accordance with (IAW) Section 2.0: Notice of the Federal Accessibility Law Affecting All Information and Communication Technology (ICT) Procurements (Section 508), Section 2.1: Section 508 – Information and Communication Technology (ICT) Standards, and Section 2.2: Compatibility with Assistive Technology. The package shall include all necessary documented artifacts that demonstrate, provide evidence, and affirm the product's compliance with Section 508 standards, ensuring the proposed solution is usable by individuals with disabilities.

The Section 508 Compliance Package shall be provided as a deliverable and updated whenever the solution is materially changed or upgraded in a manner that could affect accessibility. This package shall include, but is not limited to, the following documented artifacts:

1. A current Voluntary Product Accessibility Template (VPAT)/Accessibility Conformance Report (ACR) documenting the Contractor’s internal accessibility assessment.

2. An accessibility conformance report detailing how the product meets each applicable Section 508 requirement.

3. Documentation of any known accessibility limitations and remediation plans including timeframe for resolution.

4. All artifacts and evidence necessary to support accessibility review and testing.

5. A demonstration of Section 508 Compliance upon delivery.

The VPAT/ACR is required as part of the documentation package; however, it is accepted only as evidence of testing and does not constitute proof of Section 508 compliance.

Deliverables will be accepted based on satisfaction of Section 508 Chapter 2 standards. The Government reserves the right to test for Section 508 Compliance before delivery.

The Contractor must demonstrate full Section 508 Compliance as outlined in this Section 508 Compliance Package upon delivery.

Deliverables:

A. Section 508 Accessibility Compliance Package

ASSESSMENT AND AUTHORIZATION AND CONTINUOUS MONITORING REQUIREMNTS

1. The information system solution selected by the Contractor shall comply with the Federal Information Security Management Act (FISMA)

2. The Contractor shall remain in compliance with FedRAMP requirements as mandated by Federal laws and policies, including making available any documentation, physical access, and logical access needed to support this requirement.

3. The system must be FedRAMP Authorized at no less than the Moderate Impact Level, as mandated by Federal laws and policies, including any documentation, physical access, and logical access needed to support this requirement.

4. The Contractor shall, where applicable, assist with the VA ATO Process to help achieve agency authorization of the cloud service or migrated application.

5. The Contractor shall provide confirmation of the completion of its FedRAMP System Security Plan (SSP) and supporting documentation by providing, to the VA PM, COR, and DTC, its repository ID number and associated link for VA to download the SSP and all required artifacts within five calendar days of contract award.

6. The Contractor shall work with a VA DTC Subject Matter Expert to develop and provide a VA specific system boundary diagram including any integration and connectivity components for VA use. This will be known as the VA Implementation Diagram (VAID) and will demonstrate the proposed implementation of this system at VA.

7. The Contractor shall provide the results of their most recent Third-Party Assessment Organization (3PAO) Security Assessment Plan (SAP).

8. The Contractor shall complete a 3PAO Security Assessment Report (SAR).

9. The Contractor shall provide VA with the most recent monthly scans for the production environment within the authorization boundary and their scan upload schedule for FedRAMP within 30 calendar days of contract award.

10. The Contractor shall provide their availability to participate in monthly continuous monitoring meetings to be scheduled following successful VA ATO within 30 calendar days of contract award.

11. If new or unanticipated vulnerabilities are discovered by either VA or the Contractor, or if existing safeguards have ceased to function, the discoverer shall bring the situation to the attention of the other party within one hour in accordance with Addendum B, VA Information and Information System Security/Privacy Language.

12. The Contractor shall comply with FedRAMP data management requirements.

13. Successful issuance of a VA ATO will be required before live VA data can be used in the system.

14. The Contractor shall participate in FedRAMP Continuous Monitoring activities as outlined by FedRAMP’s Continuous Monitoring Strategy.

15. The Contractor shall participate in monthly Agency and FedRAMP Sustainment meetings following the granting of a VA ATO.

16. The Contractor shall provide continuous monitoring activities including, but not limited to scans, security artifacts, and provide Continuous Monitoring Monthly Scans and monthly Plan of Action and Milestones (POAM) reports as outlined by VA and FedRAMP requirements.

17. The Contractor shall provide a Monthly VA License Report of VA sites currently utilizing the cloud product post ATO award. The license report shall include the number of subscription licenses being utilized and the specific VA site where they’re in use.

Deliverables:

A. VA Implementation Diagram B. 3PAO Security Assessment Plan (SAP) C. 3PAO Security Assessment Report (SAR) D. Plan of Action and Milestones Reports E. Monthly VA License Report assessment and authorization (a&a) / authority to operate (ato) program management and planning The Contractor shall plan, manage, and execute all activities necessary to support VA’s RMF-based A&A process and obtain/maintain an ATO for the DLP and DAG solution throughout the lifecycle of the contract, including coordination with VA stakeholders (AO/ISSO/ISSM/CSOC/OIS) and maintain an integrated A&A master schedule.

Deliverables:

A. A&A Project Plan and Integrated Master Schedule (IMS) B. Authorization Boundary Summary and System Inventory Strategy (aligned to ConMon)

Frequency/Timeline:

A. Initial: Within 30 days of award B. Updates: Monthly and within 10 business days of major changes

RMF Security Package Development and Maintenance (Revision 5) The Contractor shall develop, update, and maintain the system security package aligned to NIST SP 800-53 Rev. 5 and VA A&A requirements, including documenting control implementation and inheritance (where applicable).

Deliverables:

A. System Security Plan (SSP) (Rev. 5 control implementation detail Control Implementation Summary/Crosswalk (VA + Moderate mappings, as applicable) B. Security architecture diagrams, boundary diagrams, and data flow diagrams Contingency Plan / DR procedures, Incident Response Plan, Configuration Management Plan, Vulnerability Management Procedures, and other required SOPs/policies.

C. ATO Package Documents

Security Control Assessment Support (3PAO/Assessor Coordination) requirement The Contractor shall support independent security assessment activities (VA-designated assessor and/or FedRamp recognized 3PAO for cloud components), including evidence collection, interviews, technical testing support, and remediation planning.

Deliverables:

A. Security Assessment Plan (SAP) support inputs B. Security Assessment Report (SAR) support inputs and evidence packages C. Updated SSP/control narratives reflecting assessment results

Continuous Monitoring (CONMON) Operations and Monthly ConMon Reporting Requirement The Contractor shall perform continuous monitoring activities and produce required ConMon deliverables at the required frequencies (monthly/annual/three-year/as needed), aligned to ConMon process areas (operational visibility, change control, incident response).

Deliverables:

A. Monthly POA&M update (with current risk posture and remediation status) B. Monthly vulnerability scan results C. Monthly inventory/asset boundary updates (as applicable) Vulnerability Scanning, Reporting, and Evidence The Contractor shall execute vulnerability scanning and reporting for in-scope components consistent with requirements, including maintaining asset-to-scan traceability and providing scan results in machine-readable formats.

Deliverables:

A. Monthly OS/infrastructure vulnerability scan reports B. Monthly web application scan reports (all web interfaces/services within boundary or AO-approved sampling) C. Monthly database scan reports (in-scope) D. Machine-readable scan outputs (e.g., CSV/XML/JSON) with CVE/CVSS details and scan configuration evidence E. Asset inventory mapping to scan results and monthly asset discovery evidence

POA&M Lifecycle Management (Creation, Tracking, Closure) The Contractor shall create, manage, and maintain POA&M items for identified vulnerabilities and control deficiencies, including root cause analysis, remediation plans, milestones, and closure evidence.

Deliverables:

A. POA&M entries for each unique vulnerability (tracked individually, not grouped), with closure packages B. Monthly POA&M status updates (as part of Configuration Mon package) significant change and security impact analysis support The Contractor shall support VA change control by preparing Security Impact Analyses (SIA), updating security package artifacts, and supporting any required out-of-cycle testing prior to implementing significant changes affecting the authorization boundary or control effectiveness.

Deliverables:

A. Security Impact Analysis (SIA) B. Updated SSP/diagrams/inventory/control narratives C. Updated Configuration Mon artifacts as required base maintenance support services The Contractor shall provide maintenance support services for all software and licenses included in section 1.1. The initial maintenance period shall commence upon VA inspection and acceptance.

Maintenance support services shall adhere to the following requirements:

1. Support services shall be available by phone 24 hours per day, 365 days per year.

2. For any issues involving a service outage impacting VA end users, the Contractor shall provide an engineer by phone to troubleshoot the issue within one (1) hour of notification.

The Contractor shall provide current versions of all software throughout the maintenance period.

Deliverable:

A. Maintenance and Support Plan documenting support availability, escalation procedures, incident response timelines, and software update schedules.

OPTION PeRIODS – Software and MAINTENANCE support SERVICES

If exercised by VA, the Contractor shall maintain the solution in accordance with PD Section 1.1 - 1.14.

DaTA AcCESS GOVERNANCE PLATFORM administration (DAG) The Contractor shall provide Resident Engineers to provide professional engineering services to increase overall system availability to include, overall software and implementation support, upgrades, troubleshooting, training, and security configuration ownership. The contractor shall comply with all the terms and conditions in this PD, including all appendices, attachments, and references, specifically including Appendix C, VA Information and Information Security and Privacy Language.

The Contractor shall:

1. Provide resident services that shall include at least two dedicated OEM technical experts.

2. Within 5 business days after award, the Contractor shall provide a roster of Contractor and Subcontractor employees to the COR to begin their background investigations and badge issuance process, in accordance with Addendum B - VA Information and Information System Security/Privacy Language. The contractor must ensure compliance with all guidelines stated in Addendum B.

3. Develop and maintain a Data Owner Access Governance Platform implementation plan, schedule, and technical approach for assigned environments.

4. Administer and sustain the enterprise collector footprint supporting the DLP and DAG capability, including installation, patching, version control, certificate management, connectivity validation, and incident remediation.

5. Participate in requirements refinement with stakeholders org, data owners, system owners, and translate into technical configurations and workflows.

a) Provide VA tailored training/brown bags for end user support staff on Storage management and support software. All training will be provided in remote virtual sessions and training materials shall be provided as needed for support staff.

6. Proactive monitoring and support for failure notifications, bugs that might affect or OEM AIOps notifications. Coordinate required actions with staff.

a) If testing is required (software, configuration), coordinate and document testing for VA change management to include implementation plan, backout plan, risk assessment and post-change configuration management documentation.

b) Utilize VA ServiceNow instance for ticket monitoring and tracking, change management.

c) Provide storage firmware, software, bug mitigation and feature enhancement testing as necessary to support new versions or security vulnerability remediation.

d) Create and maintain all standard operating procedures and upgrade or change documentation required for storage system and functional operation in VA environment.

e) Assist operations staff in performing change actions, as needed, or requested. Perform quality assurance analysis semi-annually on completed documentation and procedures, updating for versioning, changes to procedures or known bugs or configuration nuances to VA implementations.

f) No changes can be made to the products offered without written approval from the VA. All system repair / upgrade parts must be approved for incorporation by the Original Equipment Manufacturer (OEM) and must be obtain through the OEM approved distribution partners.

g) The Contractor shall provide migration services from existing software to new OEM provided software.

Deliverables:

A. Contractor Staff Roster B. Delineation of Duties for DAG C. DAG Monthly Report

DaTA AcCESS GOVERNANCE PLATFORM administration (DAG) (OPTIONAL TASK1) NTE 10 This optional task may be exercised at any time, up to two times, during the base and/or option periods to support surge operations in accordance with (IAW)requirements outlined in Section 1.14 project management The contractor shall provide a Project Manager (PM) to oversee the delivery of all goods and the completion of all professional services included in this PD.

contractor management plan The contractor shall deliver a contractor Project Management Plan (CPMP) that lays out the contractor’s approach, timeline, and tools to be used in execution of the contract. The CPMP should be a narrative and graphic format that displays the schedule, milestones, risks, and resource support. The CPMP shall also include how the contractor shall coordinate and execute planned, routine, and ad hoc data collection reporting requests as identified within the PD. The initial baseline CPMP shall be concurred upon and updated in accordance with Section B of the contract. The contractor shall update and maintain the VA PM-approved CPMP throughout the Period of Performance.

Deliverable:

A. Contractor Project Management Plan kickoff meeting Within three (3) calendar days of award, the contractor shall host a Delivery Order (DO) Kickoff Meeting with VA via telephone. Key contractor personnel involved in designing and managing the procured solutions shall be introduced to the VA Principal Architect (PA), Contracting Officer’s Representative (COR) and Program Manager (PM) at this time. A review of the contract deliverables and timetables shall occur to ensure all key VA stakeholders and contractor personnel work collaboratively together to ensure success of the DO.

NOTICE OF THE FEDERAL ACCESSIBILITY LAW AFFECTING ALL INFORMATION AND COMMUNICATION TECHNOLOGY (ICT) PROCUREMENTS (SECTION 508) On January 18, 2017, the Access Board issued a final rule that updated accessibility requirements covered by Section 508 and refreshed guidelines for telecommunications equipment subject to Section 255 of the Communications Act. The final rule went into effect on January 18, 2018. The revisions and updates to the Section 508-based standards and Section 255-based guidelines are intended to ensure that information and communication technology (ICT) covered by the respective statutes is accessible to and usable by individuals with disabilities.

SECTION 508 – INFORMATION AND COMMUNICATION TECHNOLOGY (ICT) STANDARDS

The Section 508 standards established by the Access Board are incorporated into, and made part of all VA orders, solicitations and purchase orders developed to procure ICT. These standards are found in their entirety at: Revised 508 Standards and 255 Guidelines (access-board.gov). A single PDF file version of the Revised Section 508 Standards and 255 Guidelines will be supplied upon request, or can be obtained from the Access Board website. Federal agencies must comply with the Rehabilitation Act of 1973, as amended.

The Contractor shall comply with “508 Chapter 2: Scoping Requirements” for all electronic ICT and content delivered under this contract. Specifically, as appropriate for the technology and its functionality, the Contractor shall comply with the technical standards marked here:

COMPATABILITY WITH ASSISTIVE TECHNOLOGY

The standards do not require installation of specific accessibility-related software or attachment of an assistive technology device. Section 508 requires that ICT be compatible with such software and devices so that ICT can be accessible to and usable by individuals using assistive technology, including but not limited to screen readers, screen magnifiers, and speech recognition software.

ACCEPTANCE AND ACCEPTANCE TESTING

Deliverables resulting from this solicitation will be accepted based in part on satisfaction of the Section 508 Chapter 2: Scoping Requirements standards identified above.

The Government reserves the right to test for Section 508 Compliance before delivery. The Contractor shall be able to demonstrate Section 508 Compliance upon delivery.

INFORMATION TECHNOLOGY USING SUSTAINABLE PRODUCTS

The Contractor shall comply with Sections 524 and Sections 525 of the Energy Independence and Security Act of 2007; Section 104 of the Energy Policy Act of 2005; Executive Order 14148, “Initial Rescissions of Harmful Executive Orders and Actions,” dated January 20, 2025; Executive Order 13221, “Energy-Efficient Standby Power Devices,” dated August 2, 2001; and the Revolutionary Federal Acquisition Regulation (FAR) Overhaul (RFO) to provide ENERGY STAR® certified and Federal Energy Management Program (FEMP) Designated Low Standby Power information technology products, see https://www.energy.gov/femp/search-energy-efficient-products. See http://www.energystar.gov for complete product specifications and updated lists of Energy Star certified products. FEMP low standby power product listing can be found at https://www.energy.gov/femp/low-standby-power-product-list.

The Contractor shall provide products that meet the definition of sustainable products if the products are delivered to the Government; furnished by the Contractor for use by the Government, incorporated into the construction of a public building or public work, or acquired by the Contractor for use in performing services under a Government contract where the cost of the products is a direct cost to a Government contract (versus costs which are normally applied to a contractor's general and administrative expenses or indirect costs).

Specifically, the Contractor shall provide sustainable products under this contract in accordance with RFO 52.223-23 (NOV 2025). The applicable products with their associated certification and/or designation required (e.g. Energy Star, FEMP Low Standby Power) are identified within the product requirements specifications in this PD. The Contractor shall self-certify that its proposed products meet the certification(s) and/or designation(s) specified.

SHIPMENT OF HARDWARE OR EQUIPMENT

Inspection: Destination Acceptance: Destination Free on Board (FOB): Destination

Ship To and Mark For:

Primary

Alternate

Address:

Address:

Voice:

Voice:

Email:

Email:

SPECIAL SHIPPING INSTRUCTIONS

Prior to shipping, Contractor shall notify Site POCs, by phone followed by email, of all incoming deliveries including line-by-line details for review of requirements. The Contractor shall not make any changes to the delivery schedule at the request of Site POC.

Contractors shall coordinate deliveries with Site POCs before shipment of hardware to ensure sites have adequate storage space.

All shipments, either single or multiple container deliveries, shall bear the VA IFCAP Purchase Order number (if applicable) on external shipping labels and associated manifests or packing lists. In the case of multiple container deliveries, a statement readable near the VA Integrated Funds Distribution, Control Point Activity, Accounting and Procurement (IFCAP) Purchase Order (PO) or Contract number shall indicate total number of containers for the complete shipment (e.g. “Package 1 of 2”), clearly readable on manifests and external shipping labels.

Packing Slips/Labels and Lists shall also include the following:

IFCAP PO # or Contract No.: ____________ (e.g., 166-E11234 (the IFCAP PO number is located in block #20 of the Standard Form, SF 1449)) Project Description: (e.g. Tier I Lifecycle Refresh)

Total number of Containers: Package ___ of ___. (e.g., Package 1 of 3)

NATIONAL ACQUISITIONS

Not Applicable

GENERAL REQUIREMENTS

VA TECHNICAL REFERENCE MODEL

The Contractor shall comply with the VA OIT Technical Reference Model (VA TRM). Compliance with the VA TRM is achieved by using only technologies and standards that are listed as approved for use in the VA TRM. The Contractor shall provide all necessary information requested by VA to ensure TRM approval is obtained prior to use on VA’s network.

ZERO TRUST – VA CRITICAL SECURITY CONTROLS

VA has established minimum mandatory security requirements and requires that any network connected software system or service must meet the VA Critical Security Controls as outlined in the VA Memorandum, “VA Security Controls”, https://www.voa.va.gov/DocumentView.aspx?DocumentID=5010. VA Critical Security Controls identify the minimum mandatory requirements that must be implemented across all VA enterprise infrastructure, cloud computing environments, information systems, networks, and specialized devices (medical devices/systems, special-purpose systems, and research scientific computing devices) that process, store, and/or transmit VA data. Effective July 1, 2025, the Contractor shall implement these VA Critical Security Controls, within any network connected software system or service prior to being authorized for use in the VA. This functional requirement is not negotiable, and Plan of Action & Milestones (POAM) will not be accepted in the event these controls cannot be implemented for new systems. Critical Security Controls are intended to increase VA’s security posture and provide security and privacy risk visibility into the VA network and is not a new requirement. The Contractor’s failure to maintain these VA Critical Controls after implementation will result in VA discontinuing the use of the system.

SOCIAL SECURITY NUMBER (SSN) REDUCTION

The Contractor solution shall support the Social Security Number (SSN) Fraud Prevention Act (FPA) of 2017 which prohibits the inclusion of SSNs on any document sent by mail. The Contractor support shall also be performed in accordance with Section 240 of the Consolidated Appropriations Act (CAA) 2018, enacted March 23, 2018, which mandates VA to discontinue using SSNs to identify individuals in all VA information systems as the Primary Identifier. The Contractor shall ensure that any new IT solution discontinues the use of SSN as the Primary Identifier to replace the SSN with the Integrated Control Number (ICN) in all VA information systems for all individuals. The Contractor shall ensure that all Contractor delivered applications and systems integrate with the VA Master Person Index (MPI) for identity traits to include the use of the ICN as the Primary Identifier. The Contractor solution may only use a Social Security Number to identify an individual in an information system if and only if the use of such number is required to obtain information VA requires from an information system that is not under the jurisdiction of VA.

INTERNET PROTOCOL VERSION 6 (IPV6)

The Contractor solution shall support IPv6-Only based upon the memo issued by the Office of Management and Budget (OMB) on November 19, 2020 (https://www.whitehouse.gov/wp-content/uploads/2020/11/M-21-07.pdf). Which defines IPv6-only as the state of an operational system or service when IPv4 protocol functions (addressing, packet forwarding) are not in use. The NIST USGv6 profile defines technical requirements for a product to be capable of operating in IPv6-Only environments. IPv6-Only technology, in accordance with the USGv6 Program (https://www.nist.gov/programs-projects/usgv6-program/usgv6-revision-1), NIST Special Publication (SP) 500-267B Revision 1 “USGv6 Profile” (https://doi.org/10.6028/NIST.SP.500-267Br1), and NIST SP 800-119 “Guidelines for the Secure Deployment of IPv6” (https://doi.org/10.6028/NIST.SP.800-119), compliance shall be included in all IT infrastructures, application designs, application development, operational systems and sub-systems, and their integration. In addition to the above requirements, all devices, applications, and systems shall support all applicable functionality on native IPv6-Only as well as dual stack (IPv6 / IPv4) connectivity without additional memory or other resources being provided by the Government, so that they can function in a mixed environment. All public/external facing servers and services (e.g., web, email, DNS, ISP services, etc.) shall support native IPv6-Only and dual stack (IPv6 / IPv4) users and all internal infrastructure and applications shall support using native IPv6-Only and dual stack (IPv6 / IPv4) for all functionality and operations.

SOFTWARE AND LICENSING REQUIREMENTS

The Contractor shall be responsible for the provision of all software licenses and any associated licensing maintenance required for any development, delivery, integration, operation, and/or maintenance associated with its proposed application(s), software products, software solution, and/or system including, but not limited to, any and all application(s), software and/or software products that comprise, are a part of, or integrate with the Contractor’s proposed application(s), software products, software solution, and/or system for the life of any resulting contract.

TRUSTED INTERNET CONNECTION (TIC)

The Contractor solution shall meet the requirements outlined in Office of Management and Budget Memorandum M-19-26, “Update to the Trusted Internet Connections (TIC) Initiative“ (https://www.whitehouse.gov/wp-content/uploads/2019/09/M-19-26.pdf), VA Directive 6513 “Secure External Connections”, and shall comply with the TIC 3.0 Core Guidance Documents, including all Volumes and TIC Use Cases, found at the Cybersecurity & Infrastructure Security Agency (CISA) (https://www.cisa.gov/publication/tic-30-core-guidance-documents.)

GENERATIVE ARTIFICIAL INTELLIGENCE REQUIREMENTS

If Artificial Intelligence (AI) is part of the Contractor system/solution, the Contractor shall be in compliance with E.O. 13960 and 14319, OMB Memorandums M-25-21, M-25-22, and M-26-04, and VA Directive and Handbook 6500 to support VA in trustworthy, secure, responsible, accountable, Truth Seeking, and Ideologically Neutral AI innovation.

No web-based, publicly available generative AI service has been approved for use with VA-sensitive data including, but not limited to OpenAI’s ChatGPT, Microsoft’s Copilot, Google’s Gemini, and Anthropic’s Claude. No PII, protected health information (PHI), or VA-sensitive data should be entered into these unapproved services. The entire definition of VA Sensitive Data can be found at 38 U.S.C. § 5727 (23). The Contractor shall protect VA Sensitive data from unauthorized disclosure or use, and from being used to train or improve the functionality of the vendor's commercial offerings without express permission from VA.

The Contractor shall deliver the services, technical data, configurations, models, weights, documentation or other information, including source code, developed during contract performance. The Contractor, in collaboration with VA, must evaluate the output of any AI tool for accuracy prior to using the output in VA efforts. All data, including models, weights, algorithms, and outputs generated using either Government-furnished data or data first developed under this contract shall be the property of the Government with unlimited rights as defined by FAR 52.227-14. The Contractor shall also deliver any custom-developed code developed with AI methodologies in accordance with the SHARE IT Act, if applicable. VA shall also retain unlimited rights to any improvements to that data, including the continued design, development, testing, and operation of AI systems and/or systems utilizing AI.

The Contractor shall ensure that all AI Systems, including Large Language Models (LLM), whether standalone LLMs or integrated into broader software platforms, procured under this effort and/or used in performance of this contract complies with the Unbiased AI Principles as defined in Executive Order 14319 and OMB Memorandum M-26-04, e.g. Truth Seeking and Ideologically Neutral, as applicable to the intended use of the system.

The Contractor shall ensure that AI System/LLM generated outputs are truthful in responding to user prompts seeking factual information or analysis, prioritize historical accuracy, scientific inquiry, and objectivity, as well as acknowledge uncertainty where reliable information is incomplete or contradictory and do not fabricate, hallucinate, or present unverifiable information as fact.

The Contractor shall ensure that LLMs and AI outputs are neutral, nonpartisan tools that do not manipulate responses in favor of ideological dogmas such as Diversity, Equity, and Inclusion (DEI). The Contractor shall ensure that the LLMs, including the AI System, are not intentionally encoded with partisan or ideological judgments within an AI System’s/LLM’s outputs unless those judgments are prompted by or otherwise readily accessible to the end user.

Compliance with the AI requirements of this contract, including adherence to the Unbiased AI Principles, Truth-Seeking and Ideological Neutrality requirements, disclosure obligations, monitoring and reporting requirements, and corrective action responsibilities, is a material condition of eligibility for payment and continued performance.